UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

Regulatory Docket No. _______________

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

PRECISION AERIAL SERVICES, LLC FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

TITLE 14 OF THE CODE OF FEDERAL REGULATIONS SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI Phantom 2 AND DJI Phantom 3 UNMANNED AIRCRAFT SYSTEMS

PURSUANT TO SECTION 333 OF
THE FAA MODERNIZATION AND REFORM ACT OF 2012

(PUBLIC LAW 112

- 95)

Submitted on April 20, 2015

PRECISION AERIAL SERVICES, LLC

PO Box 231

SOUTH ROCKWOOD, MI 48179

734

- 775

- 8146

bryan@precisionaerial.netTABLE OF CONTENTS

Page

GLOSSARY OF ABBREVIATIONS...................................................................................3

SUMMARY...................................................................................................................... .....4

INTRODUCTION AND INTERESTS OF PETITIONER....................................................4

BACKGROUND................................................................................................................... .4

BASIS FOR PETITION.........................................................................................................5

NAME AND ADDRESS OF PETITIONER.............................................................7

THE SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH PRECISION AERIAL SERVICES,
LLC SEEKS EXEMPTION.................................................................8

T HE EXTENT OF RELIEF PRECISION AERIAL SERVICES, LLC SEEKS AND THE REASON PRECISION AERIAL SERVICES, LLC SEEKS THE RELIEF.........................11

THE REASONS WHY GRANTING PRECISION AERIAL SERVICES, LLC ’S REQUEST
WOULD BE IN THE PUBLIC INTEREST .................... .....................................15

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT ADVERSELY
AFFECT SAFETY..........................................................................19

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER......34

AN Y ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS AVAILABLE TO
SUPPORT PRECISION AERIAL SERVICES, LLC ’S REQUEST.........34

CONCLUSION................................................................................................................... .35

APPENDIC ES........................................................................................37GLOSSARY OF ABBREVIATIONS

AGL Above Ground Level
AOI Area of Interest
ATC Air Traffic Control
ATO Air Traffic Organization
AV Aerial Vehicle
CFR Code of Federal Regulations

COA Certificate of Authoriz ation
FAA Federal Aviation Administration
FAR Federal Aviation Regulation

GCS Ground Control Station

GPS Global Positioning System
LOL Loss of Link

NAS National Airspace System

NOTAM Notice to Airman

PIC Pilot In Command

Section 3 33 FAA Modernization and Reform Act of 2012 (FMRA) Section
333

SO Safety Observer

SOP Standard Operating Procedures

UA Unmanned Aircraft

UAS Unmanned Aircraft System

VFR Visual Flight Rules

VLOS Visual Line of Site

VMC Visual Meteorological Conditions

VTOL Vertical Takeoff and LandingSUMMARY

PRECISION AERIAL SERVICES, LLC seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA). This exemption will permit PRECISION AERIAL SERVICES, LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States.

INTRODUCTION AND INTERESTS OF THE PETITIONER

PRECISION AERIAL SERVICES, LLC provides its clients w ith expertise and knowledge in aerial imaging to increase efficiency, productivity and effectiveness. PRECISION AERIAL SERVICES, LLC is operated by a licensed private pilot with valid third class medical certificate and hundreds of hours flying experience

, knowledge of National Airspace System requirements and regulations, see and avoid principles, and a keen interest in safely sharing the nation’s airspace with manned aircraft . He has 2 years recreational experience in safe operation of remote control air craft and quadcopters in accordance with federal, state, and local regulations and established industry safe practices. The objective of PRECISION AERIAL SERVICES, LLC and its aerial operations is to provide high quality imaging for a variety of commercial , public, and residential uses, specifically targeting:

• Construction sites progression

• Appraisals

 Special event recording (wedding and other gatherings)

• Real

- estate marketing

• Aerial acquisitions used for inspections of public and private

structures.

• Infrastructure i nspection operationsBACKGROUND

Unmanned Aircraft Systems: DJI Phantom 2, DJI Phantom 3 UASs

PRECISION AERIAL SERVICES, LLC seeks an exemption to operate DJI systems for compensation or hire within the NAS. The DJI Phantom 2 and DJI Phantom 3 are vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or smart phone systems. The DJI Phantom 2 has a maximum gross weight of approximately 2 pounds 11 oun ces, while having a length of 16 inches width of 16 inches, height of 8 inches, and a maximum speed of approximately 29 knots. The DJI Phantom 3 has a maximum gross weight of 6 pounds 7.5 ounces, a length of 17.3 inches, width of 17.7 inches, height of 11. 8 inches, and a maximum speed of approximately 42 knots. The DJI Phantom 2 and DJI Phantom 3 UAs are equipped with four main rotors; driven by Lithium Polymer battery powered electric motors.

The DJI Phantom 2 and DJI Phantom 3 UAs that will be operated b y PRECISION AERIAL SERVICES, LLC will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft , as well as 14 C.F.R Part 47, Aircraft Registration , and marked in accordance with 14 C.F.R. Part 45, Identification and Registration Marking

.

BASIS FOR PETITION

Petitioner, PRECISION AERIAL SERVICES, LLC , pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems , hereby petitions the Administrator to commercially operate the DJI Phantom 2, DJI Phantom 3 UASs in the National Airspace System (NAS), and for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, PRECISION AERIAL SERVICES, LLC operation of DJI Phantom 2 and DJI Phantom 3 UASs meets the conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Accordingly, PRECISION AERIAL SERVICES, LLC requests relief from Sections 91.40 5(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate.PRECISION AERIAL SERVICES, LLC submits that the requested relief is pro per since an

equivalent level of safety will be ensured. PRECISION AERIAL SERVICES, LLC will use experienced personnel or technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices pr escribed in the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 and DJI Phantom 3 Instruction Manual). Furthermore, PRECISION AERIAL SERVICES, LLC will document and maintain all maintenance records for the DJI Phantom 2 and DJI Phanto m 3
UASs.

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges and limitations: Pilot in command , is requested by PRECISION AERIAL SERVICES,
LLC to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as well as an airman medical certificate, and who has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC
is a ble to safely operate the DJI Phantom 2 and DJI Phantom 3 UASs in a manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

PRECISION AERIAL SERV ICES, LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness

, because the DJI Phantom 2 and DJI Phantom 3 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. As such,
PRECISION AERIAL SERV ICES, LLC submits that it will ensure that the DJI Phantom 2 and DJI Phantom 3UASs are in an airworthy condition, prior to every flight, by determining that the UASs are in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Pha ntom 2 and DJI Phantom 3 Instruction Manual), and that the aircraft are in a condition for safe flight.

PRECISION AERIAL SERVICES, LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings , as the DJI Phantom 2 and D JI Phantom 3 UAs will not have a typical barometric altimeter onboard. However, altitude information of the DJI Phantom 2 and DJI Phantom 3UAs will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with PRECISION AERIAL SERVICES, LLC ’s operation of the DJI Phantom 2 and DJI Phantom 3 UASs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121.

Additionally, PRECISION AERIAL SERVICES, LLC seeks an exemption from the requirements of Section 91.151(b), entitled Fuel requirements for flight in VFR conditions

. PRECISION
AERIA L SERVICES, LLC submits that safety will not be affected by operation of the DJIPhantom 2 and DJI Phantom 3 UAs during daylight hours in visual meteorological

conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total d uration of approximately 14.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

In accordance with 14 C.F.R. § 11.81, PRECISION AERIAL SERVICES, LLC provides the following infor mation in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is:

PRECISION AERIAL SERVICES, LLC

PO Box 231

South Rockwood, MI 48179

734

- 775

- 8146

precisionaerial@gmail. com

B. The Specific Sections Of 14 C.F.R. From Which PRECISION AERIAL SERVICES,
LLC Seeks Exemption.

1. PRECISION AERIAL SERVICES, LLC Seeks Exemption From The Requirements Of Section 61.113(a) And (b).

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command

, subsections (a) and (b) prescribe the following, in relevant part:

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an aircraft that is carrying passenge rs or property for compensation or hire; nor may that person, for compensation or hire, act as PIC of an aircraft.

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any business or employment if

— (1) The flig ht is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire.2. PRECISION AERIAL SERVICES, LLC Seeks Exemption From The Requirements Of Section 91.7(a).

Section 91.7, entitled Civil aircraft airworthiness , subsection (a), states the following:

(a) No person may operate a civil aircraft unless it is in an airworthy condition.

3. PRECISION AERIAL SERVICES, LLC Seeks Exemption From The Requirements Of Section 91.121.

Section 91.121, entitled Altimeter settings , subsection (a), states the following, in part:
(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating

--
(1) Below 18,000 feet MSL, to

--

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of the aircraft;

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an appropriate altimeter setting available before depart ure.

4. PRECISION AERIAL SERVICES, LLC Seeks Exemption From The Requirements Of Section 91.151(b).

Section 91.151, entitled Fuel requirements for flight in VFR conditions , subsection

(b), states the following:(b) No person may begin a flight in a ro torcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

5. PRECISION AERIAL SERVICES, LLC Seeks Exemption From The Requirement Of Section 91.405(a).

Section 91.405, entitled Maintenance required , subsection (a), states the following: Each owner or operator of an aircraft

— (a) Shall have that aircraft inspected as prescribed in s ubpart E of this part and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.]

6. PRECISION AERIAL SERVICES, LLC Seeks Exemption From The Requireme nts Of Section 91.407(a)(1)

Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration

, subsection (a)(1), states the following:

(a) No person may operate any aircraft that has undergone maintenance, preventiv e maintenance, rebuilding, or alteration unless

-- (1) It has been approved for return to service by a person authorized under § 43.7 of this chapter[.]

7. PRECISION AERIAL SERVICES, LLC Seeks Exemption From The Requirements Of Sections 91.409(a)(1) And 9 1.409(a)(2).

Section 91.409, entitled Inspections , subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had

-- (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.8. PRECISION AERIAL SERVICES, LLC Seeks Exemption From The Requirements Of Sections 91.417(a) And 91.417(b).

Section 91.417, entitled Maintenance records , subsections (a) and (b), state the following:

(a) Except for work performed i n accordance with §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section:

(1) Records of the maintenance, preventive maintenance, and alteration and records of th e 100

- hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

-- (i) A description (or refer ence to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and

(iii) The signature, and certificate number of the person approving the aircraft for return to service.

(2) Records containin g the following information:

(i) The total time in service of the airframe, each engine, each propeller, and each rotor.

(ii) The current status of life

- limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis.

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspe ction program under which the aircraft and its appliances are maintained.

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revisio n date. If the AD or safetydirective involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the airframe and currently installed engines , rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed:

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by oth er work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold.

(3) A list of defects furnished to a registered owner o r operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service.

C. The Extent Of Relief PRECISION AERIAL SERVICES, LLC Seeks And The Reason PRECISION AERIAL SERVICES, LLC Seeks The Relief.

1. Extent Of Relief PRECISION AERIAL SERVICES, LLC Seeks And The Reason PRECISION AERIAL SERVICES, LLC Seeks Relief From Section 61.113(a) And (b).

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations : Pilot in command , is requested to the extent necessary to allow a PIC holding a private pilot or higher level certificate, as well as a current and valid airman medical certificate, and who has met certain flight

- hour and currency requirements, to conduc t the proposed UAS flight operations for compensation or hire.

This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a private pilot may, for compensation or hire, act as PIC of an aircraft in connection with
any business or employment if: (1) The flight is only incidental to that business or employment; and (2) The aircraft does not carry passengers or property for compensation or hire.

As set forth more fully below, PRECISION AERIAL SERVICES, LLC submits that a n equivalent level of safety will be maintained because no PIC will be allowed to operate the DJIPhantom 2 UAS or DJI Phantom 3 UAS unless that PIC has met certain flight

- hour and

currency requirements, demonstrating that the PIC is able to safely operate either the DJI Phantom 2 or DJI Phantom 3 UAS in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well as maintaining appropriate distances from people, vessels, vehicles and

structures.

Further, PRECISION AERIAL SERVICES, LLC submits that all flights of the DJI Phantom 2 and DJI Phantom 3 UASs, conducted by the PIC pursuant to the grant of this Petition: (1) will be incidental to PRECISION AERIAL SERVICES, LLC ’s business; and (2) will not carry passengers or property for compensation or hire.

2. Extent Of Relief PRECISION AERIAL SERVICES, LLC Seeks And The Reason PRECISION AERIAL SERVICES, LLC Seeks Relief From Section 91.7(a).

Relief from Section 91.7(a) entitled Civil aircraft airworthiness , is requested to the extent required to allow PRECISION AERIAL SERVICES, LLC to determine that the DJI Phantom 2 and DJI Phantom 3 UASs are in airworthy condition prior to every flight by ensuring that the UAS is in compliance with t he operating documents (i.e., the PRECISION AERIAL SERVICES, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Phantom 3 Instruction Manual).

PRECISION AERIAL SERVICES, LLC seeks the requested relief because the DJI Phantom 2 and DJI Phantom 3 UASs do not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, PRECISION AERIAL SERVICES, LLC will ensure that the DJI Phantom 2 and DJI Phantom 3 UASs are in airworthy condition based upon its compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Phantom 2 and DJI Phantom 3 Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the condition s and limitations below.

3. Extent Of Relief PRECISION AERIAL SERVICES, LLC Seeks And The Reason PRECISION AERIAL SERVICES, LLC Seeks Relief From Section 91.121.

Relief from Section 91.121, entitled Altimeter settings , may be required to allow flight operations of the DJI Phantom 2 and DJI Phantom 3 UASs, which utilize a barometric pressure sensor, GPS equipment, and a radio communications telemetry data link todownlink altitude information from the UA to the PIC at t he ground control station (GCS).

Since the FAA requires that any altitude information concerning UAS operations be reported to air traffic control (ATC) in feet above ground level (AGL), PRECISION AERIAL SERVICES, LLC seeks the requested relief because the DJI Phantom 2 and DJI Phantom 3 UA’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field altitude, before each flight.

Considering the limited altitude of the proposed operations, relief from 14 CFR 91. 121 is sought to the extent necessary to comply with the applicable conditions and limitations stated below. As more fully set forth herein, an equivalent level of safety will be maintained since the DJI Phantom 2 and DJI Phantom 3 UAs are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, and provides the PIC with altitude information of the UA on the heads

- up display of the GCS.

4. Extent Of Relief PRECISION AERIAL SERVICES, LLC Seeks And The Reason PRECISION AERIAL SERVICES, LLC Seeks Relief From Section 91.151(b).

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions , is requested to the extent required to allow flights of the battery powered DJI Phantom 2 and DJI Phantom 3 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a total duration of 14.5 minutes to the first point of intended landing and, a ssuming normal cruising speed, to fly after that for at least 4.5
minutes. PRECISION AERIAL SERVICES, LLC seeks the requested relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Phantom 2 and DJI Phantom 3 UAs will severely constrain the practicality of any aerial video or still photo flight operations that PRECISION AERIAL SERVICES, LLC proposes to conduct pursuant to this Petition.

Significantly, as set forth below, the technical specifications of the DJI Phantom 2 and DJI Phantom 3 UASs, the DJI Phantom 2 and DJI Phantom 3 operating documents, and PRECISION AERIAL SERVICES, LLC ’s proposed operating limitations, ensure that PRECISION AERIAL SERVICES, LLC will safely operate the battery powered DJ I Phantom 2 and DJI Phantom 3 UAs during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), with enough battery power to fly for a total duration of 14.5 minutes to the first point of intended landing and, assuming n ormal cruising speed, to fly after that for at least 4.5 minutes.5. Extent Of Relief PRECISION AERIAL SERVICES, LLC Seeks And The Reason PRECISION AERIAL SERVICES, LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a ) & (b).

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply to aircraft with an airworthiness certificate, PRECISION AERIAL SERVICES, LLC requests relief from these Sections because the DJI Phantom 2 and DJI Pha ntom 3 UASs do not require airworthiness certificates. As set forth more fully below, the DJI Phantom 2 and DJI Phantom 3 UASs meet the conditions of FMRA Section 333 for operation without an airworthiness certificate. Accordingly, PRECISION AERIAL SERVICE S, LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the PRECISION AERIAL SERVICES, LLC Aerial Operation s Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Phantom 3 Instruction Manual). Furthermore, PRECISION AERIAL SERVICES, LLC will document and maintain all maintenance records for the DJI Phantom 2 and DJI Phantom 3 UASs.

D. The Reasons Why Gra nting PRECISION AERIAL SERVICES, LLC Request Would Be In The Public Interest; That Is, How It Would Benefit The Public As A Whole.

Granting the present Petition will further the public interest by allowing PRECISION AERIAL SERVICES, LLC to safely, effici ently, and economically perform aerial video and photography of construction sites, real estate, and landscape over certain areas of the United States.

Additionally, use of the DJI Phantom 2 and DJI Phantom 3 UASs will decrease congestion of the NAS, redu ce pollution, and provide significant benefits to the economy. Notably, the benefits of PRECISION AERIAL SERVICES, LLC ’s proposed operation of the DJI Phantom 2 and DJI Phantom 3 UASs will be realized without implicating any privacy issues.

1. The Public Will Benefit From Decreased Congestion Of The NAS.

The DJI Phantom 2 and DJI Phantom 3 UAs are battery powered and serve as a safe, efficient, and economical alternative to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing t he amount of manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI Phantom 2 or DJI Phantom 3 UASwould reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as

well as increase the safety of life and property in the air and on the ground.

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion around airports caused by arriving and departing aircraft will be reduced. The
DJI Phantom 2 and DJI Phantom 3 UAs d o not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting aerial video and photography missions would result in fewer aircraft that must be handled by air traffic control during the ground, takeoff, departure, arrival , and landing phases of flight operations.

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Phantom 2 and DJI Phantom 3 UASs.

Conducting aerial acquisitions with the DJI Phantom 2 and DJI Phantom 3 UASs, instead of manned aircraft, will greatly benefit the public by drastically reducing the levels of air and noise pollution generated during traditional aerial video and still phot ography flight operations. By using battery power and electric motors, the DJI Phantom 2 and DJI Phantom 3 UASs produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engi ne aircraft that are typically utilized for aerial video and photography, while burning approximately
10

- 2 0 gallons per hour of leaded aviation fuel. The DJI Phantom 2 and DJI Phantom 3 UAs, while reducing the carbon footprint of aerial acquisitions, also eliminates noise pollution, as the UAs are propelled by battery powered electric motors, rather than an internal combustion engine.

By using the DJI Phantom 2 and DJI Phantom 3 UASs to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft flight operations, will be substantially reduced or completely eliminated. Aside from the lack of flight crew members located onboard the aircraft, the DJI Phantom 2 and DJI Phantom 3 UAs (weighing approximately 2 pounds 11 ounces and 6 pounds 7.5 ounces respectively, at their maximum gross weights with lengths of 16 inches and 17.3 inches respectively, widths of 16 inches and 17.7 inches respectively, and with no fu el on board), has less physical potential for collateral damage to life and property on the ground, and in the air, compared to the manned aircraft that typically conduct similar operations (weighing approximately 6,000 pounds with a wingspan of approximat ely 42 feet, a length of 34 feet, and a fuel capacity of 180 gallons).

3. Performing Aerial Video and Photography Operations With The DJI Phantom 2 and DJI Phantom 3 UASs Will Benefit The Economy.In addition to being safe and efficient, the DJI Phantom 2 and DJI Phantom 3 UASs are

also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Phantom 2 and DJI Phantom 3 UASs will allow United States based companies, like PRECISION AERIAL SERVI CES, LLC , to remain competitive and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel and phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in order to remain competitive. Operating the battery powered DJI Phantom 2 and DJI Phantom 3 UASs is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, but provides such flexibility without the high operat ional cost of a traditional manned aircraft.

By operating the DJI Phantom 2 and DJI Phantom 3 UASs, companies such as PRECISION AERIAL SERVICES, LLC , can remain competitive and profitable, and therefore, provide greater job stability to employees and cont ractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Phantom 2 and DJI Phantom 3 UASs, provides a stable workforce that increases consumer spending; imp roves local, state, and federal tax revenues; and allows companies to invest in research and development in order to remain competitive both in the United States and abroad.

4. There Are No Privacy Issues.

Similar to the manned aerial acquisition flight operations that have been conducted for decades, PRECISION AERIAL SERVICES, LLC ’s proposed operation of the DJI Phantom 2 and DJI Phantom 3 UASs will not implicate any privacy issues. Specifically, the DJI Phantom 2 and DJI Phantom 3 UASs will be operated only in compliance with operating documents (i.e., the PRECISION AERIAL SERVICES, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Phantom 3 Instruction Manual) which requires property owner involvement as well as local law enforcement notification, and in accordance with the Federal Aviation Regulations, including the minimum altitude requirements of 14 C.F.R. § 91.119.

E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or How The Exemption Would P rovide A Level Of Safety At Least Equal To That Provided By The Rule From Which PRECISION AERIAL SERVICES, LLC Seeks Exemption.1. Reasons Why The DJI Phantom 2 and DJI Phantom 3 UAs Meet The Conditions Of The FAA Modernization and Reform Act of 2012 (FM RA) Section 333.

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, PRECISION AERIAL SERVICES, LLC ’s operation of the DJI Phantom 2 and DJI Phantom 3 UASs meet the conditions o f FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H.

Section 333 provides authority for a UAS to operate without airworthiness certification and sets forth requirements for considering whet her a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 states the following, in part:

(a) In General.

-- Notwithstanding any other requirement of this subtitle, and n ot later than 180 days after the date of enactment of this Act, the Secretary of Transportation shall determine if certain unmanned aircraft systems may operate safely in the national airspace system before completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act.

(b) Assessment of Unmanned Aircraft Systems.

-- In making the determination under subsection (a), the Secretary shall determine, at a minimum

-- (1) which types of unmanned aircra ft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual line of sight do not create a hazard to users of the national airspace system or the public or pose a threat to national security; and

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification under section 44704 of title 49, United States Code, is required for the operation of unmanned aircraft systems identifi ed under paragraph (1).(c) Requirements for Safe Operation.

-- If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the saf e operation of such aircraft systems in the national airspace system.

In seeking this exemption, PRECISION AERIAL SERVICES, LLC submits that the DJI Phantom 2 and DJI Phantom 3 UASs can operate safely in the NAS pursuant to FMRA Section 333, as demonstra ted by: (a) the characteristics of the DJI Phantom 2 and DJI Phantom 3 UASs; (b) the pilot certification requirement; and (c) the specific operating limitations.

a. The Specifications Of The DJI Phantom 2 and DJI Phantom 3 UASs Demonstrate Its Safe Characteristics.

The DJI Phantom 2 and DJI Phantom 3 UASs do not create a hazard to users of the NAS or the public, or otherwise pose a threat to national security considering its size, weight, speed, and operational capability.

i. Technical Specificatio ns Of The DJI Phantom 2 and DJI Phantom 3
UASs.

The technical specifications of the DJI Phantom 2 and DJI Phantom 3 UASs are set forth by the DJI Phantom 2 and DJI Phantom 3 User Manuals, attached hereto as Appendix A and
B.

ii. The DJI Phantom 2 and DJ I Phantom 3 UASs Autonomous Flight

And Navigation Modes Enable The UASs To Remain Within A Defined Operational Area.

The DJI Phantom 2 and DJI Phantom 3 UASs may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Phantom 2 and DJI Phantom 3 UASs is provided at pages 25

- 35 of the DJI Phantom 2 and pages 12

- 16 and 45

- 50 of the DJI Phantom 3 User Manuals, attached hereto as Appendix A and B.iii. The DJI Phantom 2 and DJI Phan tom 3 UASs Are Designed For Automatic Return To Home Point Or Hover In The Event Of Loss Of The Control Link Or Navigation.

When the Control Link is lost, the DJI Phantom 2 and DJI Phantom 3 UAs will remain stationary, in flight, for 3 seconds or more. I f, after 3 seconds, the DJI Phantom 2 and DJI Phantom 3 UAs do not reacquire control link data from the GCS, the UAs will assume that the Control Link is lost and the UAs will return to the home position (i.e., failsafe mode) via GPS, and will descend to t he takeoff position and shutdown.

A complete description of the Failsafe Functions of the DJI Phantom 2 UAS are set forth at pages 27 through 29 and for the DJI Phantom 3 at pages 13 through 15 of the DJI Phantom 2 and DJI Phantom 3 User Manuals, attached hereto as Appendix A and B.

iv. The DJI Phantom 2 and DJI Phantom 3 GCS And Its Operation.

A complete description of the operation and specifications of the DJI Phantom 2 and DJI Phantom 3 GCS and flight control software is provided at pages 32 through 43 of the DJI Phantom 2 User Manual and pages 40 through 47 of the DJI Phantom 3 User Manual. DJI Phantom 2 and DJI Phantom 3 User Manuals are attached hereto as Appendix A and B.

b. Flight Operations Of DJI Phantom 2 and DJI Phantom 3 UASs Are Limited T o The Line Of Sight Of A Certificated Pilot in Command With A Safety Observer.

PRECISION AERIAL SERVICES, LLC will be the only person to act as a pilot in command (PIC) of the DJI Phantom 2 and DJI Phantom 3 UASs. Additionally, a safety observer will

ass ist him during flight time.

c. Flights Of DJI Phantom 2 and DJI Phantom 3 UASs Will Be Conducted Pursuant To Specific Operating Limitations.

In seeking this exemption, PRECISION AERIAL SERVICES, LLC proposes to commercially operate DJI Phantom 2 and DJI Phantom 3 UASs for the special purpose of conductingaerial video and photography over certain areas of United States, pursuant to the

following specific operating limitations:

1. Operations authorized by this grant of exemption will be limited to the fol lowing aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum gross weight: DJI Phantom 2 and DJI Phantom 3 Unmanned Aircraft Systems. Proposed operations of any other aircraft will require a new petition or a p etition to amend this grant.

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography.

3. The UAs may not be flown at an indicated airspeed exceeding 20 knots.

4. The UA must be operated at an altitude of no more than 500 feet above ground level (AGL), as indicated by the procedures specified in the operating documents unless a special request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL.

5. The UAs must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA

- issued airman medical certificate.

6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted.

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. ThePIC must be designated before the flight and cannot transfer his or her designation for the duratio n of the flight. The PIC must ensure that the SO can perform the functions prescribed in the operating documents.

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding other air traffic and other ground based obsta cles/obstructions and is not permitted to operate the camera or other
instruments.

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exist s between the conditions and limitations contained in the grant of exemption and the procedures outlined in the operating documents, the conditions and limitations contained in the grant of exemption take precedence and must be followed. Otherwise, the ope rator must follow the procedures as outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised documents to the Administrator

u pon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exe mption, then the operator must petition for amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

80) may be contacted if questions arise regarding updates or revisions to the operating documents.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly documented in the aircraft records.11. Any UAS that has undergone maintenance o r alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records.

12. The pre

- flight inspection must account for all potential discrepancies, e.g. inoperable components, items, or equipment, not already covered in the relevant sections of the operating documents.

13. The operator must follow the UAS manufacturer’s aircraf t/component, maintenance, overhaul, replacement, inspection, and life limit requirements.

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service.

15. Each UASs operated under this exemption must comply with all manufacturer Safety Bulletins.

16. The authorized person must make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

17. The PIC must possess at least a private pilot certificate and at least a current third

- class medical certificate.

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s qualification criteria and demonstrates the ability to safely operatethe UAS in a manner consistent with how the UAS will be operated under the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures. PIC qualification fligh t hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs are permitted under the terms of the exemption. However, training operations may only be conducted during dedicated training s essions. During training, proficiency, and experience

- building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F .R. § 91.119.

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations must be conducted under visual meteorological conditions (VMC). If flight at night is required, a special request will be made at the FAA of fice closest to proposed area of operations. Flights under special visual flight rules (SVFR) are not authorized.

20. The UA may not operate within 5 nautical miles of an airport reference point as denoted on a current FAA

- published aeronautical chart un less a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM as required by the operator’s COA. The letter of agreement with the airport management must be made available to the Administra tor upon request.

21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

22. If the UA loses communications or loses its GPS signal, it mus t return to a
pre

- determined location within the planned operating area and land or be recovered in accordance with the operating documents.23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in accordance with the op erating documents.

24. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power

rema ining.

25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airm an (NOTAM) not more than 72 hours in advance, but not less than 48 hours prior to the operation. All operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential tran sponder requirements.

26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N

- Number) markings in accordance with 14 C.F.R. part 45, Subp art C. Markings must be as large as practicable.

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate government oversigh t agency requirements.

28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the UAS is operating. These documents must be made available to the Administrator or
any law enforcement official upon request.29. The UA must remain clear and yield the right of way to all manned aviation operations and activities at all times.

30. The UAS may not be operated by the PIC from any moving device or
vehicle.

31. Flight operations must be conducted at least 500 feet from all nonparticipating persons (persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless:

a. Barriers or structures are present that suf ficiently protect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protectio n and are within 500 feet of the UA, flight operations must cease immediately and/or;

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller of such vessels, vehicles or structures has granted permission and the PIC h as made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard, and;

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present an undue hazard to those persons per § 91.119(a).

32. All operations shall be conducted over private or controlled

- access property with permission from the land owner/controller or authorized representative. Permission from land owner/controller or authorized representative wil l be obtained for each flight to be conducted.33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Off ice (AFS

- 80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov.

2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) Woul d Not Adversely Affect Safety.

PRECISION AERIAL SERVICES, LLC submits that the equivalent level of safety established by Section 61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Phantom 2 and DJI Phantom 3 UASs unles s that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate the DJI Phantom 2 or DJI Phantom 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and ma intaining appropriate distances from people, vessels, vehicles and structures.

Considering PRECISION AERIAL SERVICES, LLC ’s proposed area of operations, and the operating limitations set forth

- above; the parallel nature of private pilot aeronautical knowl edge requirements to those of commercial pilot requirements ( See Exemption No. 11062); and the airmanship skills necessary to safely operate the DJI Phantom 2 or DJI Phantom 3 UAS, PRECISION AERIAL SERVICES, LLC submits that the additional manned airmanshi p experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for PRECISION AERIAL SERVICES, LLC ’s specific proposed flight operations.

The FAA has previously granted relief from Section 61.113(a) and (b) specifi c to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11158, 11159, 11160, 11161).

PRECISION AERIAL SERVICES, LLC will not allow any PIC to operate the DJI Phantom 2 or DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour requirements or the DJI Phantom 2 or DJI Phantom 3 UAS training and currency requirements, that t he PIC is able to safely operate the DJI Phantom 2 or DJI Phantom 3UAS in a manner consistent with this exemption, including evasive and emergency

maneuvers and maintaining appropriate distances from people, vessels, vehicles and

structures.
Specifically , the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. § 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes).

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was obtained in compliance with applicable regulations will ensure an equivalent level of safety during PRECISION AERIAL SERVICES, LLC ’s proposed operations. The Administrator has held that prior documented flight experience that was obtained in compliance with applicable regulations would ensure safe operations, stating as follows:

In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose of motion picture filming (or similar operations), the PIC must have accumulated an d logged, in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot including at least 10 hours logged as a UAS pilot with a multi

- rotor UAS. Prior to operations under Exemption No. 11062, the PIC must also have accumula ted and logged a minimum of 5 hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be inclusive rather than additive; i.e. 5 hou rs make and model time may be included in the 10 hours of multi

- rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the flight

- hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience

- building flights can also be conducted under the grant of exemption to acc omplish the required flight time. During training, proficiency, and experience

- building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119.Exemption No. 11138 at page 15.

Accordingly, PRECISION AERIAL SERVICES, LLC will ensure safe operations by not allowing any PIC to operate the DJI Phantom 2 or DJI Phantom 3 UAS unless that PIC has demonstrated, by meeting minimum flight

- hour and currency requirements, that the PIC is able to safely operate th e DJI Phantom 2 or DJI Phantom 3 UAS in a manner consistent with the exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures.

3. Reasons Why An Exemption From The Requirement s Of Section 91.7(a) Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.7(a) will be maintained because prior to every flight, PRECISION AERIAL SERVICES, LLC will ensure that the DJI Phantom 2 or DJI Phantom 3 UAS is in an airworthy condition based upon the UAS’s compliance with its operating documents and as stated in the conditions and limitations herein.

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in
circumstances s imilar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not Adversely Affect Safety.

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Phantom 2 and DJI Phantom 3 UAs will be provided to the PIC via GPS equipment and a radio communications telemetry data link, which downlinks from the UA to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with PRECISION AERIAL SERVICES, LLC ’s operation of the DJI P hantom 2 and DJI Phantom 3 UAs within visual line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information will be generated by GPS equipment installed onboard the aircraft. Prior to each flig ht, a zero altitude initiation point is automatically established by the UASs at ground level.

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. E xemptionNos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138,

11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not Adversely Affect Safety.

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b) as a result of (1) the technical specifications of the DJI Phantom 2 and DJI Phantom 3 UASs; (2) the limitations on the proposed flight operati ons; and (3) the location of the proposed flight operations. Accordingly, PRECISION AERIAL SERVICES, LLC will ensure that it will safely operate the battery powered DJI Phantom 2 and DJI Phantom 3 UAs during daylight hours in VFR conditions, with enough ba ttery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes.

Here, as in Exemption No. 11109, the technical specifications of the DJI Phanto m 2 and DJI Phantom 3 UASs; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety will be ensured as the DJI Phantom 2 and DJI Phantom 3 UASs provide audible and visual warnings to the PIC at the GCS when the UAs experiences low battery voltage, the first warning occurring at approximately 33% remaining battery power, and again at approximately 10% remaining bat tery power. At the critically low battery level, the DJI Phantom Vision+ and DJI Phantom 3 UASs will descend and land automatically.

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish that safety is not adversely aff ected when the technical characteristics and operating limitations of the UAS are considered. Relief has been granted for manned aircraft to operate at less than the minimums prescribed in Section 91.151, including Exemption Nos. 2689, 5745, and 10650. Mor eover, the FAA has previously granted relief from Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161).

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety.In seeking this exemption, PRECISION AERIAL SERVICES, LLC submits that the equivalent

level of safety with regard to the regulatory maintenance and alteration requirements established by Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because PRECISION AERIAL SERVICES, LLC will use trained technicians to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the operating documents (i.e., the
P RECISION AERIAL SERVICES, LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Phantom 2 and DJI Phantom 3 Instruction Manual). Furthermore, PRECISION AERIAL SERVICES, LLC will document and maintain all maintenance records for the DJI Phantom 2 a nd DJI Phantom 3 UASs.

Since the DJI Phantom 2 and DJI Phantom 3 UASs will be inspected as prescribed by the operating documents, PRECISION AERIAL SERVICES, LLC will maintain the equivalent level of safety established by Sections 91.405(a), 91.409(a)(1), and 91.409(a)(2). A copy of the DJI Phantom 2 and DJI Phantom 3 User Manuals are attached hereto as Appendix A and B; a copy of the DJI Phantom 2 and DJI Phantom 3 UAS Maintenance LOG is attached hereto as Appendix C.

Likewise, the exemption sought will n ot adversely affect safety because PRECISION AERIAL SERVICES, LLC will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating documents.

Fur thermore, the exemption sought would maintain an equivalent level of safety established by Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Phantom 2 and DJI Phantom 3 UASs will be performed by trained technicians.
Maintenance w ill be documented and maintained utilizing the monthly maintenance log.

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely af fected when the technical characteristics and operating limitations of the UAS are
considered.

In consideration of PRECISION AERIAL SERVICES, LLC ’s proposed operating limitations, the operating documents, and the technical aspects of the DJI Phantom 2 and DJI Phantom 3 UASs, PRECISION AERIAL SERVICES, LLC submits that safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted rel ief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. ExemptionNos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136,

11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 1116 1).

7. The FAA May Prescribe Any Other Conditions For Safe Operation.

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions

, PRECISION AERIAL SERVICES, LLC requests that the FAA prescribe special conditions for the intended operation of the DJI Phantom 2 and DJI Phantom 3 UASs, which contain such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that establi shed by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 (a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). Such special conditions will permit safe operation of the UAs for the limited purpose o f conducting aerial video and photography over certain areas of the United States for compensation or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification in accordance with any requirements that must be established for the safe operation of the UAS in the NAS.

Likewise, the Admini strator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for operation of the DJI Phantom 2 and DJI Phantom 3 UASs, since the airworthiness regulations of 14 C.F.R. Part 21 do not contain adequate or appropriate safety standards, due to the novel or unusual design features of the aircraft. Section 21.16, entitled Special Conditions , states the following:

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or appropriate safety standards for an aircr aft, aircraft engine, or propeller because of a novel or unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance with Par t 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or propeller as the FAA finds necessary to establish a level of safety equivalent to that established in the regulations.

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA may prescribe special conditions for Leading Edge’s intended operation of the DJI Phantom 2and DJI Phantom 3 UASs, which contain such safety standards that the Administrator fin ds

necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

• A Summar y That Can Be Published In The Federal Register, stating: The Rules From Which PRECISION AERIAL SERVICES, LLC Seeks Exemption:

PRECISION AERIAL SERVICES, LLC seeks exemption from the requirements of 14 C.F.R Sections 61.113(a)&(b), 91.7(a), 91.121, 91.15 1(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b).

A Brief Description Of The Nature Of The Exemption PRECISION AERIAL SERVICES, LLC Seeks:

This exemption will permit PRECISION AERIAL SERVICES, LLC to commercially operate an Unm anned Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain areas of the United States.

• Any Additional Information, Views, Or Arguments Available To Support PRECISION AERIAL SERVICES, LLC ’s Request.

This Petit ion is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, PRECISION AERIAL SERVICES,
LLC ’s request for exemptio n may be granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth above.

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; and further, provides the authority for such UAS to operate without airworthiness certification.As discussed in detail above, PRECISION AERIAL SERVICES, LLC will operate the DJI Phantom 2 and DJI Phantom 3 UASs safely in th e NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a threat to national security.

CONCLUSION

As set forth herein, PRECISION AERIAL SERVICES, LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Phantom 2 and DJI Phantom 3 UASs commercially, without an airworthiness certificate, for t he limited purpose of conducting aerial video and photography over certain areas of the United States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests of the public, by allowing PRECISION AERIAL SERVICES, LLC to safely, efficiently, and economically operate the DJI Phantom 2 and DJI Phantom 3 UASs commercially within the NAS.

WHEREFORE , in accordance with the Federal Aviation Re gulations and the FAA Modernization and Reform Act of 2012, Section 333, PRECISION AERIAL SERVICES, LLC respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 9 1.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), and permit PRECISION AERIAL SERVICES, LLC to operate the DJI Phantom 2 and DJI Phantom 3 UASs commercially for the purpose of conducting aerial video and photography ove r certain areas of the United
States.

Dated: September 3, 2015

Respectfully submitted,

PRECISION AERIAL SERVICES, LLC

_________________________ PRECISION AERIAL SERVICES, LLC

PO Box 231

South Rockwood, MI 48179

734

- 775

- 8146

bryan@precisionaerial.netAppendices :

A

– DJI Phantom 2 Manual:

B

– DJI Phantom 3 Specifications Data Sheet

C

– Monthly Maintenance Log

D

- DJI Phantom Users Guide

APPENDIX

– A

DJI PHANTOM 2 VISION+ TECHNICAL SPECIFICATIONS

PRECISION AERIAL SERVICES, LLC only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspa ce. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

- time altitude and location information to the PIC via the linked monitor (smart phone/tablet devices)

1.1 DJI Phantom 2 Vision+

1.1.1 Aircraft 1.1.1.1 Supported Battery

– DJI 5200mAH LiPo Battery 1.1.1.2 Weight (Battery & Propellers Included)

– 2lbs 11.810oz (1242g)

1.1.1.3 Hover Accuracy (Ready to Fly)

– Vertical: .8m; Horizontal: 2.5m 1.1.1.4 Max Yaw Angular Velocity

- 200 0 /s 1.1.1.5 Max Tilt Angel

- 35 0
1.1.1.6 Max Ascent Speed

– 6m/s 1.1.1.7 Max Descent Speed

– 2m/s 1.1.1.8 Max Flight Speed

– 15m/s (NOT RECOMMENDED)1.1.2 Gim bal 1.1.2.1 Working Current

– Static: 750mA; Dynamic: 900mA 1.1.2.2 Control Accuracy

- ±0.03 0
1.1.2.3 Controllable Range

– Pitch:

- 90 0

- 0 0
1.1.2.4 Maximum Angular Speed

– Pitch: 90 0 /s

1.1.3 Camera 1.1.3.1 Operating Temperature Range

- 32 0 F

- 104 0 F (0 0 C

- 40 0 C)

1.1.3.2 Sensor Size

– 1/2.3”

1.1.3.3 Effective Pixels

– 14M

1.1.3.4 Resolution

– 4384x3288 4.1.3.5 HD Video Recording

– 1080p30 & 720p 4.1.3.6 Recording Field of View

- 110 0 /85 0

1.1.4 Transmitter
1.1.4.1 Operating Frequency

– 5.728GHz

– 5.85GHz
1.1.4.2 Communication Distance (unobstructed)

– FCC Compliance: 800m
1.1.4.3 Receiver Sensitivity (1%PER)

- - 93dBm

1.1.4.4 Transmitter Power

– FCC Compliance: 100mW 1.1.4.5 Working Voltage

– 120mA@3.7V

1.1.5 Range Extender
1.1.5.1 Operating Frequency

– 24 12

- 2462MHz
1.1.5.2 Communication Distance (unobstructed)

– 500

- 700m

1.1.5.3 Transmitter Power

– 20dBm
1.1.5.4 Power Consumption

– 2WAPPENDIX

– B DJI Phantom 3 TECHNICAL SPECIFICATIONS

PRECISION AERIAL SERVICES, LLC only utilizes safe and reliable UASs. DJI is an industry leader in small UAS production. DJI UASs are loaded with ground breaking software enabling the user to set parameters which will not allow flight into controlled airspace. Parameters can also be set to limit flight to no higher than a predetermined and set altitude as well as limit flight to a predetermined and set distance. In addition, DJI software provides real

- time altitude and location information to the PIC via the linked monitor (smart phone/t ablet devices)

2.2 DJI Inspire 1

2.2.1 Aircraft

2.2.1.1 Model

– Phantom 3 2.2.1.2 Weight (Battery Included)

– 1280 grams 2.2.1.3 Hovering Accuracy (GPS Mode)

– Vertical: +/

- 10cm ; Horizontal: +/

- 1m 2.2.1.4 Max Angular Velocity

– Yaw: 20 0 0 /s

2.2.1.5 Max Tilt Angle

- 35 0
2.2.1.6 Max Ascent Speed

– 5m/s 2.2.1.7 Max Descent Speed

– 3 m/s 2.2.1.8 Max Speed

– 16 m/s (ATTI mode, no wind

– NOT RECOMMENDED) 2.2.1.9 Max Flight Altitude

– 60 00m

2.2.1.1 0 Max Flight Time

– Approximately 23 minutes

2.2.1.12 Motor Model

– DJI 3510 2.2.1.13 Propeller Model

– DJI 1345 2.2.1.14 Operating Temperature Range

– 14 0 F to 104 0 F (

- 10 0 C to 40 0 C)

2.2.1.15 Dimensions

– 17 1⁄4” x 17 3⁄4” x 12”

2.2.2 Gimbal

2.2.2.1 Model

– ZENMUSE X3 2.2.2.2 Output Power (with camera)

– Static: 9W; In Motion: 11W2.2.2.3 Operating Current

– Static: 750mA; In Motion: 900mA 2.2.2.4 Angular Vibration Range

- ±0.03 0
2.2.2.5 Mounting

– Detachable 2.2.2.6 Controllable Range

– Pitch:

- 90 0 to +30 0 ; Pan: ± 320 0
2.2.2.7 Mechanical Range

– Pitch:

- 125 0 to 45 0 ; Pan: ± 330 0
2.2.2.8 Max Controllable Speed

– Pitch: 120 0 /s; Pan: 180 0 /s

2.2.3 Camera

2.2.3.1 Name

– Sony EXMOR

2.2.3.2 Model

– 12.4M Pixel

2.2.3.3 Total Pixels

– 12. 4 M

2.2.3.4 Effective Pixels

– 12. 76 M 2.2.3.5 Image Max Size

– 4000x3000
2.2.3.6 ISO Range

– 100

- 3200

2.2.3.7 Field of View

- 94 0

2.2.3.8 CMOS

– Sony EXMOR 1/2.3” 2.2.3.9 HD Video Recording

– UHD(4K): 4096x2160p24/25, 3840x2160p24/25/30; FHD: 1920x1080p24/25/30/48/50/60; HD: 1280x720p24/25/30/48/50/60 2.2.3.10 Operating Temperature Range

- 32 0 F

- 104 0 F (0 0 C

- 40 0 C)

2.2.4 Transmitter

2.2.4.1 Name

– C1 2.2.4.2 Operating Frequency

– 5.728

- 5.850GHz; 2.400

- 2.483GHz 2.2.4.3 Communicating Distance (unobstructed)

– 2000m
2.2.4.4 Output Power

– 9W 2.2.4.5 Operating Temperature Range

- 14 0 F to 104 0 F (

- 10 0 C to 40 0 C)
2.2.4.6 Battery

– 600mAh LiPo 2S